Specialized Disclosure Report (Form SD)

Exhibit 1.01

SYNTEC OPTICS HOLDINGS, INC.

Conflict Minerals Report

For The Calendar Year Ended December 31, 2025

Introduction

This Conflict Minerals Report (this "Report") of Syntec Optics Holdings, Inc. for the calendar year ended December 31, 2025 (the "Reporting Period") is filed in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"), which was adopted by the Securities and Exchange Commission (the "SEC") to implement the reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"), and pursuant to the Company's Specialized Disclosure Report on Form SD ("Form SD") for the Reporting Period filed with the Securities and Exchange Commission (the "SEC"). The Rule imposes certain reporting and disclosure obligations on SEC registrants for which cassiterite, columbite-tantalite, gold, wolframite or their derivatives, which are limited to tin, tantalum and tungsten ("conflict minerals"), are necessary to the functionality or production of a product manufactured or contracted to be manufactured by the registrant. References in this Report to "Syntec Optics," the "Company," "we" or "our" refer to Syntec Optics Holdings, Inc. and its subsidiaries, on a consolidated basis, unless otherwise indicated or the context otherwise requires.

Company and Product Overview

Syntec Optics Holdings, Inc. (Nasdaq: OPTX), headquartered in Rochester, NY, is one of the largest custom and diverse end-market optics and photonics manufacturers in the United States. Operating for over two decades, Syntec Optics runs a state-of-the-art facility with extensive core capabilities across various optics manufacturing processes, both horizontally and vertically integrated, to provide a competitive advantage for mission-critical OEMs. As more products become light-enabled, Syntec Optics continues to add new product lines, including recent Low Earth Orbit (LEO) satellite optics for communications, AI data-center power, and reconnaissance, multi-spectral optics for deep tech, as well as display and sensing for Artificial Intelligence-driven AR/VR systems. According to SPIE Optics and Photonics Global Industry Report 2024, across the entire field of optics and photonics, the monetary value of all light-enabled products and related services accounts for over 15% of worldwide economic output (nearly $16 trillion of the total $106 trillion value of all finished goods and services produced worldwide in 2023).

Design of Conflict Minerals Program

Syntec Optics' due diligence framework with regards to conflict minerals, which is summarized below, conforms to the Organization for Economic Co-operation and Development ("OECD") Guidance for Responsible Supply Chains for Minerals from Conflict-Affected and High Risk Areas and the Supplements on Tin, Tantalum and Tungsten and on Gold.

Step 1 - Establish strong company management systems

Step 2 - Identify and assess risks in the supply chain

Step 3 - Design and implement a strategy to respond to identified risks

Step 4 - Perform audit of the supply chain

Step 5 - Report annually on supply chain due diligence internally to management

Description of Due Diligence Measures Performed

● Sent Conflict Minerals Reporting Template ("CMRT"), a standardized reporting template developed by the Responsible Minerals Initiative ("RMI"), request to suppliers and expectations of them to cooperate in providing due diligence information, and requested that suppliers return a completed CMRT.

● Contacted suppliers who returned the CMRT that require follow-up based on internally defined criteria.

Results of Our Due Diligence Measures

Syntec Optics uses tin, tantalum, tungsten, and gold ("3TG") in the design and manufacture of some of its products and is therefore a "downstream" company in the conflict minerals supply chain. Due to the nature of our supply chain, we do not typically have a direct relationship with 3TG smelters and refiners ("SORs"). Our manufacturing operations employ a wide variety of semiconductors, electromechanical components, and raw materials that are also supplied by other downstream companies in the supply chain. Our due diligence process involves seeking data from our relevant suppliers, and these suppliers also seek similar information from their supply chain in order to identify the sources for the necessary conflict minerals. We rely on the good faith efforts of our supply chain to provide reasonable data. We achieved a response rate of 94% for our supply chain survey conducted for the calendar year ended December 2025.

Many of our suppliers sourced 3TG from a variety of upstream sources and provided information to Syntec Optics on an aggregated, company-wide level. Due to the fungible nature of these materials, we understand that these suppliers were unable to trace the 3TG that they source into the products provided to any particular customers (including Syntec Optics). As a result, our list of SORs may contain more facilities than are actually used in our supply chain. In addition, our list of SORs may not include all the SORs in our supply chain, as our suppliers were unable to identify the SORs of some of the conflict minerals. To the extent reasonably possible, Syntec Optics has documented the country of origin of identified smelters and refiners based on information received through the Conflict-Free Smelter Program ("CFSP"), surveys of smelters and refiners, and/or reviews of publicly available information.

As a result, as of December 31, 2025, we have included a possible list of a total of 344 SORs that could be in our 2025 supply chain (See Appendix A), as our suppliers either were unable to provide SOR information or provided SOR information that could not be verified. Syntec Optics intends to continue to evaluate and improve our due diligence program and engage with our suppliers to identify the origin and chain of custody of 3TG minerals in our products with an aim to achieve a Conflict Free Supply Base.

As previously noted, because of the nature of our supply chain, we do not typically have any direct relationship with 3TG SORs. Therefore, as noted above, we contributed to the improvement of SOR diligence practices by working through our supply chain.

Ongoing Improvement Efforts

For the next reporting period, we intend to continue taking steps to further mitigate the risk that conflict minerals that are necessary to the functionality or production of our products finance or benefit armed groups in the Democratic Republic of the Congo or adjoining countries, (together, the ("DRC").

These steps include:

● work with relevant suppliers to update their conflict minerals reporting template using the latest CMRT and verify the identified smelters with RMI's most current list;

● continue to refine our conflict minerals program to improve our reasonable due diligence measures in our efforts to determine the source and chain of custody of conflict minerals;

● continue to work with suppliers and others on industry-wide solutions to enable products that are DRC conflict free; and

● extend Reasonable Country of Origin Inquiry ("RCOI") and due diligence measures to any of our recently acquired entities and businesses.